Trudeau Civil Case Documents 767 0 Thru 768 Re Coercive Incarceration

7/27/2019 Trudeau Civil Case Documents 767 0 Thru 768 Re Coercive Incarceration

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GIN Network Truth (the smart group)

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

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Case No. 03-C-3904

Hon. Robert W. Gettleman

FTCS MOTION FOR LEAVE TO FILE A REPLY

IN SUPPORT OF COERCIVE INCARCERATION

In light of the importance of this litigation and the specific issue before Court, Plaintiff

Federal Trade Commission (FTC) respectfully requests leave to file a reply in support of

coercive incarceration. The FTCs proposed reply is attached hereto.

The FTC has noticed this motion for the already-scheduled hearing on Wednesday, when

the court will address the consequences of defendants violations[.] Order (DE760) (Sept. 26,

2013). The proposed reply concerns this issue.

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Dated: October 14, 2013

David OToole ([email protected])Federal Trade Commission55 West Monroe Street, Suite 1825Chicago, Illinois 60603-5001Phone: (312) 960-5601Fax: (312) 960-5600

Respectfully Submitted,

/s/ Jonathan CohenMichael Mora ([email protected])Jonathan Cohen ([email protected])Amanda B. Kostner ([email protected])Federal Trade Commission600 Pennsylvania Ave., N.W. M-8102BWashington, DC 20580Phone: 202-326-3373; -2551; -2880

Case: 1:03-cv-03904 Document #: 767 Filed: 10/14/13 Page 1 of 2 PageID #:13684


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CERTIFICATE OF SERVICE

I, Jonathan Cohen, hereby certify that on October 14, 2013, I caused to beserved true copies of the foregoing by electronic means, by filing such documents through theCourts Electronic Case Filing System, which will send notification of such filing to:

Kimball Richard Anderson

[email protected]

Thomas Lee Kirsch, [email protected]

Katherine E. [email protected]

Blair R. [email protected]

/s/ Jonathan Cohen

Jonathan Cohen ([email protected])Attorney for Plaintiff

Federal Trade Commission



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Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

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Case No. 03-C-3904


FTCS REPLY IN SUPPORT OF COERCIVE INCARCERATION

The primary question before the Court is whether Trudeau should receive yet another

second chance to disclose his assets voluntarily, or whether the Court should give coercive

incarceration the opportunity to work so that his victims can obtain redress. Trudeau supports

the former alternative with three legally meritless and factually fictional points addressed below.

A. TRUDEAU HAS NOT BEEN COOPERATIVE OR CANDID WITH THECOURT OR THE RECEIVER.

First, Trudeau claims to have fully cooperated with the Receiver, DE766 at 1 (Oct. 10,

2013), notwithstanding the Courts contrary finding that he has not been fully cooperative or

candid with the Receiver, DE751 (Sept. 18, 2013) at 1, and also notwithstanding the mountain

of evidence supporting the Courts finding. At this point, it is beyond reasonable argument that

Trudeau has not been fully cooperative and candid: (1) his most recent filing reflects a lack of

candor; (2) his new order violations prove that he has not been fully cooperative; and (3) his

implausible explanations concerning his assets further illustrate his continued refusal to be

forthcoming.

1. TRUDEAUS MOST RECENT FILING ILLUSTRATES HIS LACKOF CANDOR.

Two examples from Trudeaus most recent filing demonstrate that, even now, Trudeau

continues his dishonesty. First, Trudeau writes: Throwing caution to the wind, however, the

Case: 1:03-cv-03904 Document #: 767-1 Filed: 10/14/13 Page 1 of 11 PageID #:13686


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FTC speculates without any factual basis that Trudeau may have received$4.2 million. But noevidence exists that Trudeau received such a transfer. Trudeaus Br. at 9 (Trudeaus emphasis).

But one need only look at Exhibit 9 to Trudeaus filing to see that he received at least

$4,305,452.43 for infomercials since 2007. Specifically, Exhibit 9 shows $4,305,452.43 in wire

transfers from third party infomercial producers to Trustar Productions, Inc (Trustar). See Ex.

9, DE766 (Oct. 11, 2013). The Court found that Trudeau controls Trustar,1 which is one of

multiple entities Trudeau controlled through Isle of Man-based KMT Fiduciary Trust.2 See

PXA:1. Amazingly, Trudeau still maintains that no evidence exists that he received this

money. See Trudeau Br. at 9 (emphasis added). Through Trustar, however, he did receive the

money. Trudeaus claim that no evidence exists that he received more than $4 million is one

of many bald assertions in his brief that are demonstrably false.

Second, Trudeau dismisses his 2012 purchase of two pairs of cufflinks (for $12,470.99)

by attributing the purchase to his wife, see Trudeau Br. at 11 n.2 (representing that the cufflinks

were purchased by [his] wife), notwithstanding his 2013 sworn financial statement in which he

denied any knowledge concerning his wifes jewelry. See DE535 (Jan. 25, 2013) at 7.3

In any

event, as part of his story, Trudeau refers to the cufflinks as womens cufflinks, id. (emphasis

added), although nothing in the Ebay invoice indicates they are womens cufflinks, see

PXA:27, DE764-3 (Oct. 4, 2013). In fact, simply looking at them strongly suggests that they are

not womens cufflinks,4 and Ebay sells them as mens jewelry.5 Suffice it to say, Trudeau

1See DE729 (July 26, 2013) at 1; DE713 at 6 (July 15, 2013) (proposed findings of fact

regarding Trustar Productions).2 TRUCOM owns Trustar Productions, which is owned by K.T. Corporation Limited,

which is owned by KMT Fiduciary Trust. See PXA:1.

3 Specifically, Item 17 on the sworn financial statement form (page 6 of the form) asksTrudeau to disclose other personal property, including jewelry. See DE535 (Jan. 25, 2013)at 7. With respect to his wife, he wrote: UNKNOWN. See id.

4See PXA:2 (webshots); www.christies.com/lotfinder/jewelry/patek-philippe-a-pair-of-

18k-white-5167196-details.aspx (viewed Oct. 12, 2013). Due to the government shutdown, theFTC will forward a copy of this filing (and the exhibits) to chambers via Federal Express.

5See PXA:3 at 2 (webshots); www.ebay.com/itm/Patek-Philippe-18K-White-Gold-

Diamond-Ellipse-Cufflinks-/151060790543 (viewed Oct. 12, 2013).



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makes no attempt to explain why his wife needed Neil Sant (Trudeaus right-hand man) to

purchase two pairs of cufflinks for her through Trudeaus Ebay account, see DE764-3 (Oct. 4,

2013), or why she isnt even copied on the email regarding her cufflinks (the email is from

Sant to Trudeau, see id.). Moreover, no amount of forensic accounting will find $12,000 worth

of easily-hidden cufflinks. The fact that this issue concerns only $12,000 does not detract from

its significance: even now, Trudeau remains untruthful.

2. TRUDEAUS CONTINUED ORDER VIOLATIONS SHOW HISLACK OF COOPERATION.

Trudeau argues that he has corrected his five new order violations or, alternatively, they

are not serious enough to warrant coercive sanctions. This misses the point. These violations

demonstrate that Trudeau has not been honest and forthcoming. His dishonesty has ramifications

beyond the individual lies and order violations that come to light. Specifically, the Receiver

cannot marshal Trudeaus assets if he is willing to lie and continue violating orders even with

respect to relatively small amounts of hidden funds. For example:

The Non-Disclosure of the Australian Account. Trudeau could not havereasonably believed that his opaque reference to this account as having less than$1500 net of liabilities qualified as sufficiently candidparticularly when hispurported disclosure did not include the account number, or the banks address,

or even the country where the bank is located. See DE525 at 4 (Jan. 25, 2013).

Spending from the Australian Account. Trudeau could not have reasonablybelieved that it was acceptable to spend thousands from this accountnotwithstanding the Courts asset freeze. Most important, he didnt stop until hegot caught.

Destruction of Documents. Trudeau could not have reasonably believed thatdeleting emails was consistent with order provisions prohibiting him fromdestroying documents. See DE742 (Aug. 7, 2013) at 13. The fact that he agreedto stop once he got caught does not lessen the violations significance.

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The Non-Disclosure of the On-Line Gaming Account. Trudeau could not havereasonably believed that waiting six weeks to disclose the on-line gamblingaccount was consistent with the receivership order. The fact that he eventuallydisclosed it (under questioning from the Receiver) does not make his priornondisclosure any more honest.

6 Trudeau observes that [t]he FTC is unable to identify any relevant or materialdocuments that were destroyed. Trudeau Br. at 6. This is truemost likely, no one ever willknow what was lost precisely because Trudeau destroyed the documents.



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Lying to the Receiver. Trudeaus claim that there are no hidden assetsanywhere in the world was indisputably false. See Receivers Supp. Report(DE750-1) (Sept. 16, 2013) (attaching Sept. 7 email from Trudeau). Additionally,the fact that Trudeau later provided log-in information for his Australian accountdoes not take away from the fact that he initially denied having it. See id. at 2.

For the receivership to have any hope of working, Trudeau has to be fully cooperativenot

simply admit to specific facts after he gets caught. In short, the Court correctly found that

Trudeau has not been fully cooperative or candid with the Receiver, DE751 (Sept. 18, 2013) at

1, and none of his halfhearted explanations regarding these incidents should change that

conclusion.

3. TRUDEAUS IMPLAUSIBLE STORIES REGARDING HISASSETS ILLUSTRATE HIS LACK OF CANDOR.

a. Trudeaus Dubious Explanations Regarding Offshore Activity.Trudeau controls at least three active offshore bank accounts. After reviewing extensive

evidence, the Court found that Trudeau controls the Global Information Network (GIN) and

various affiliated entities, including Global Information Network FDN (GIN FDN) and

Website Solutions Switzerland (WSS).7 Based on information the Receiver obtained, between

January 1 and September 6 of this year, nearly $16 million flowed into GIN FDN accounts, and

nearly $17 million flowed out. See PXA:4, Receivers Supp. Report (DE750-1) (Sept. 16, 2013)

at 25-26. There are at least two GIN FDN accounts: one at Valartis Bank (Lichtenstein), see

PXA:5 (wire information), and one at National Westminster Bank (U.K.), see PXA:6 (wire

information). The Court may recall both accounts from the evidentiary hearing. For instance,

Trudeau used the National Westminster account to pay Marc Lane, PXA:7, and when he was

attempting to set up the Liechtenstein account, he gave instructions to Sant about how he should

answer the banks likely questions regarding Babenkos role, PXA:8. Later, in 2011, Trudeau

asked Sant: how much [money] is in Liechtenstein? PXA:9. Sant responded:

$3,523,838.30. Id.

7See DE729 (July 26, 2013) at 1; DE713 at 14-16 (July 15, 2013) (proposed findings of

fact regarding GIN FDN and WSS).



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In addition to the GIN FDN accounts, WSS also has an account. Trudeau instructed Sant

to wire money from Lichtenstein to WSS, PXA:10 (which means WSS must have had an

account), and Trudeau received a supposed salary from WSS as recently as July, see Ex. 8,

Trudeau Br. (which further establishes that WSS has a bank account).8

The money in GIN FDN

and WSS accounts belongs to the Receivership, see DE742 (Aug. 7, 2013) at 4, and should be

turned over immediately. Trudeaus refusal to do so underscores his lack of cooperation.

With respect to the many other offshore entities, Trudeau calls the FTC analysis pure

conjecture. Trudeau Br. at 8. But the power of attorney Trudeau received from N.T. Trading

S.A. is not conjectureit is an exhibit to the FTCs prior filing. See FTC Statement, PXA:9

(also attached hereto as PXA:12). Trudeaus refusal to allow Lane to have the power of attorney

revoked is also not conjecture, see PXA:13, and strongly suggests that Trudeau was undertaking

some sort of activity with N.T. Trading. In fact, with respect to Hong Kong entity NBT Trading

Ltd., Trudeau gave this instruction to Sant less than a year ago: [T]he ari deal should NOT be

in my personal nameit should be with nbt trading limitedcan you have ar[i] redo it under

that name please[?]9

PXA:15 (emphasis added). Nevertheless, Trudeau continues to maintain

that he knows essentially nothing about NT Trading, NBT Trading, or various other offshore

entities, and that they were created solely so that he would have shell companies he could use

later. See FTC Statement at 7-8. Trudeaus continued denials and fictional explanations

regarding these entities further highlights his lack of candor.

b. Trudeaus Dubious Explanations Regarding Gold.Sticking with his refrain, Trudeau argues that the gold bars and coins belong to Natalia

Babenko. Trudeau Br. at 8. However, Trudeau ignores the evidence that at least $100,000 used

to pay for the gold bars came from an account in his name.10

PXA:16. On one invoice, Trudeau

8When interviewed, Trudeau referred to WSS as a legitimate company that had little to

do with him. PXA at 29. As the Court may recall, Website Solutions Switzerland was part ofTrudeaus original vision that he conveyed to Marc Lanes firm in 2009. PXA:11.

9 Ari apparently refers to Ari Wasserman, who produced and distributed various ofTrudeaus infomercials. See Trudeau Br., Ex. 9.

10 Trudeau also ignores his sworn financial statement, in which he denied knowing



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is listed under the billed to and shipped to name, PXA:17 at 1, and every invoice shows the

bars (or coins) going either to Trudeaus Ojai home or his 130 Quail Ridge Drive business

address, see PXA:17. Trudeau also fails explain the email from Golden Lion Mint (GLM)

referring to one gold shipment as Kevins package. PXA:18 (emphasis added). In fact, in

another email, GLM writes to Trudeau: I thought we could get the ball rolling on your gold

and silver. PXA:19 (emphasis added). Babenko is not copied. See id. With respect to the

2011 exchange of GLM bars for more readily-transferable Scotia Bank bars, GLM sent Trudeau

this email:

Hi Kevin!

Were hoping to see your GLM bars soon.

Like I mentioned, we have pre-sold five bars.

Any ideas when well see them?

Thanks!

PXA:20 (emphasis added).11

Again, Babenko isnt copied (or even mentioned). See id.

Trudeau then forwarded this email to Sant with the instruction: Neilwork this out with the

gold. See id. Once again, Babenko is not copied or mentioned. See id.

Put simply, Trudeau bought, controlled, and almost certainly continues to possess

significant gold and other precious metals worth hundreds of thousands of dollars. Trudeaus

claim that these were his wifes transactions is another instance in which he continues to deceive

the Court and the Receiver.

whether his wife had coins or other gold. Specifically, Item 17 on the sworn financial statement

form (page 6 of the form) asks Trudeau to disclose other personal property, including coinsand bullion. See DE535 (Jan. 25, 2013) at 7. With respect to his wife, he wrote:UNKNOWN. See id.

11GLM managers Peter Lundell and Tony Balistreri have a close relationship with

Trudeau. Trudeau apparently arranged for them to present a GIN seminar, see PXA:19 (Wereexcited about doing a GIN event too!), and there are records reflecting a $1,994 payment forevent tickets by Natural Cures to Roaring Lion Publishing, another company associated withLundell and Balistreri. See PXA:21 (Natural Cures Bills Due printout); PXA:18 (emailsignature line Roaring Lion Publishing/Golden Lion Mint).



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c. Trudeaus Dubious Explanations Regarding Transfers.Trudeau does not even attempt to explain GINs books (which suggest both he and his

wife received substantial transfers). These transfers include $149,051.82 to Babenko this year,

PXA:4, and $16,305.79 to an account in Antigua as recently as August 20. See Receivers Supp.

Report (DE750-1) (Sept. 16, 2013) at 2. Trudeau denies any knowledge about this transfer, but

the problem is that these transfers to Babenko came from GIN FDN, see PXA:4the Nevis-

organized entity that the Court found Trudeau controls.12

There are other suspicious transfers as

well, including $644,727.70 (this year) to Office Pool GmbH, PXA:4, a Swiss firm that helps

people move to Zurich, obtain local drivers licenses and bank accounts, and establish offices.13

In fact, this January, Office Pool funneled money back to Lane from an account at Credit

Suisse. PXA:24. Trudeau, however, informed the Receiver that he was only an employee and

that he knows little about Website Solutions Switzerland, PXA 29despite the fact that WSS

was part of the original vision he conveyed to Marc Lanes firm, see PXA:11, and despite the

fact that Trudeau directed payments from GIN FDN to WSS, see PXA:10. Simply put, Trudeau

has not been honest or forthcoming.14

B. TRUDEAU WILL HOLD THE KEYS TO HIS RELEASE.Second, Trudeau suggests that the Court cannot coercively incarcerate him because the

FTC, not the Court, will hold the keys to Trudeaus release, DE766 at 1 (Oct. 10, 2013), but

this ignores the purge conditions the Court identified would obtain if Trudeau failed to

12See DE729 (July 26, 2013), DE713 at 14 (July 15, 2013) (proposed findings of fact).

13See PXA:22 (web shots); www.officepool.ch (viewed Oct. 13, 2013). Additionally,

GIN FDN made significant payments this year to both Marc Lane and Winston & Strawn. SeePXA:4. Notably, GIN FDN also disbursed $129,692.34 this year to W.P. Barlow, see id., a

retired Texas attorney who lobbied a former FTC Commissioner and a high ranking FTC staffmember to discourage the FTC from aggressively pursuing this litigation, PXA:23.14 This is the issue with the Ukrainian apartment as well. See FTC Statement at 8.

Trudeau claims he was not directly involved with paying the mortgage on the apartment, seeTrudeau Br. at 9. In reality, however, he was substantially involved. See PXA:25 ([A]re we allsquare with [t]he kiev apartment? Natalie wants to sell itGIN wants to buy itthoughts?)(Trudeaus ellipses); PXA:26 ([C]onfirm that we are paying off the apartment in Kiev.).Trudeau argues that he cannot turn over the apartment, but the immediate issue is the fact that hehas not been completely forthcoming with the Receiver or the Court about his role.



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cooperate. The receivership order specifies the precise purge conditions that will govern

Trudeaus incarceration:

It is further ordered that Trudeaus failure to comply fully and timely with thisorder will result in Trudeaus immediate incarceration until (A) such compliance

is achieved; (B) Trudeau fully complies with this Courts June 2, 2010 order(DE372); (C) Trudeau establishes that he has no present ability to comply withthe Courts June 2, 2010 order; or (D) Trudeau establishes that continuedincarceration will not coerce him to comply with the Courts June 2, 2010 order.

DE742 (Aug. 7, 2013) at 20. Accordingly, if Trudeau persuades the Court that he has honestly

disclosed everything he knows, and thus can do nothing further to comply, then the Court should

release him immediately because he will have satisfied purge conditions (A) and (C).

Significantly, this framework gives Trudeau the option to provide full cooperation at any

time, and gives the Court (not the FTC or the Receiver) discretion to determine whether that

cooperation has been achieved. In fact, other courts have used purge conditions similar to these

when confronted with contumacious defendants like Trudeau. For instance, in CFTC v. Trimble,

No. 09-154, 2009 U.S. Dist. LEXIS 102197 (W.D. Okla. Nov. 2, 2009), the Court stated that

Trimble could obtain his release by complying with various orders, including an order that he

provide full and complete disclosure regarding both his and his wifes assets. See id.

(emphasis added). Likewise, inAndrews v. Holloway, 256 F.R.D. 136 (D.N.J. 2009), the court

found that civil confinement is the only appropriate and effective sanction for Defendants

contemptuous conduct, and ordered the contemnor to remain in custody until he provides

complete and honest testimony regarding his assets. Id. at 151 (emphasis added). The purge

conditions here are essentially the sameTrudeau must satisfy the Court that he has been candid

and forthcoming, and therefore there is nothing further he can do to comply.

Importantly, the fact that it may be difficult for Trudeau to satisfy the Court is a problem

Trudeau created. Trudeau has no one but himself to blame for his four contempts and lies to the

Court stretching back to 1999. This history may make it more difficult for Trudeau to establish

that he has candidly disclosed everything he knows about assets he controls, but it does not make

it impossible (he might start by abandoning the fiction that assets ranging from gold bars to



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cufflinks belong to his wife). Additionally, Trudeau spent several years (and millions of dollars)

implementing various asset protection techniques designed to create the appearance of poverty

while making the assets he controls as difficult as possible to locate and retrieve.15 Again,

however, even if Trudeaus decision to undertake these efforts makes it more difficult for him to

establish that he has candidly disclosed everything he knows, it does not make it impossible. 16

Rather, after imposing coercive sanctions, the Court should judge whether Trudeau has said and

done everything he can. If the Court is satisfied, then he should be immediately released.

C. THE CONSUMER-FUNDED FORENSIC ACCOUNTING IS NOT ABASIS TO PROVIDE TRUDEAU WITH YET ANOTHER SECONDCHANCE.

Finally, the Receivers proposed consumer-funded forensic accounting is not a basis to

give Trudeau yet another final opportunity to avoid coercive sanctions. The proposed forensic

accounting is, at best, a supplement to what Trudeau knows about assets he controlsit is not a

new basis for him to defer the consequences of his deceit once again. Worse, not only will a

forensic accounting take considerable time (which itself works to consumers substantial

detriment), the forensic accounting will be funded with assets that would otherwise go to

consumer redress. The notion that consumers should pay to find assets Trudeau hid from them is

hard to accept and, most important, it is not what the Court ordered. Rather, the Court ordered

that if Trudeau fail[ed] to comply fully and timely, it would result in his immediate

incarceration. DE742 (Aug. 7, 2013) at 20. The Court did not allow him the luxury of waiting

months until a forensic accounting is completed, nor should the Court do so.

15The difficulty with untangling asset protection efforts is the primary reason why courts

faced with contemnors like Trudeau use coercive incarceration: asking them to disclose theirassets voluntarily doesnt work, and untangling an intentionally-constructed web of obscuretransactions and offshore entities is either impossible or prohibitively expensive. See, e.g.,In reLawrence, 279 F.3d 1294, 1296-97 (11th Cir. 2002) (affirming incarceration of defendant whoused asset protection trust); FTC v. Affordable Media, LLC, 179 F.3d 1228, 1241-43 (9th Cir.1999) (same); SEC v. Solow, 682 F. Supp.2d 1312, 1334 (S.D. Fla. 2010) (incarceratingcontemnor who engaged in various asset protection techniques).

16Notably, Trudeau is correct about one thing: the fact that the FTC doesnt believe him

is irrelevant. What matters is whether the Court believes him.



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David OToole ([email protected])Federal Trade Commission55 West Monroe Street, Suite 1825Chicago, Illinois 60603-5001Phone: (312) 960-5601

Fax: (312) 960-5600


/s/ Jonathan CohenMichael Mora ([email protected])Jonathan Cohen ([email protected])Amanda B. Kostner ([email protected])Federal Trade Commission

600 Pennsylvania Ave., N.W. M-8102BWashington, DC 20580Phone: 202-326-3373; -2551; -2880Fax: 202-326-2551



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Kimball Richard Anderson

[email protected]




/s/ Jonathan CohenJonathan Cohen ([email protected])

Attorney for PlaintiffFederal Trade Commission



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Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

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Case No. 03-C-3904


EXHIBIT IN SUPPORT OF

FTCS REPLY IN SUPPORT OF COERCIVE INCARCERATION



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FTC

EXHIBIT A



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FTC PXA:1



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FTCX 13-LPXA:1 at 1



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FTCX 13-LPXA:1 at 5



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FTC PXA:2



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12 December

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Lot Description

PATEK PHILIPPE. A PAIR OF 18K WHITE GOLD AND DIAMOND CUFFLINKSSIGNED PATEK PHILIPPE, GENEVE,NAUTILUS, CIRCA 2005The 18k white gold Nautilus-style cufflinks with sapphire crystal, black-grey center, diamond-set front22mm width

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2000sJewelrycufflinks, buttons & studsdiamondgoldSwitzerlandModern

Lots In This SalePATEK PHILIPPE. A VERY FINE AND RARE 18KSIGNED PATEK PHILIPPE & CO., GENEVE, MOVEMENT NO. 867360, CASE NPr. $272,500

PATEK PHILIPPE. A LADY'S 18K GOLD ANDSIGNED PATEK PHILIPPE, GENEVE, CALATRAVA, MOVEMENT NO. 1613572,Pr. $17,500

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Patek Philippe 18K White Gold Diamond Ellipse Cufflinks

(Click to Enlarge)

Patek Philippe 18K White Gold Diamond Ellips e Cufflinks

Condition: Brand New

Brand: Other Brands

Retail Price: $7,700.00

Reference: J002001

Web ID: 22510

Stock Number: 1001300

Gender: Gents

Metal: 18K White Gold

Weight: 18 grams

Stones: Diamonds: 0.40 ct.

Color/Clarity: G VS1

Signatures: Patek Philippe, Geneve, Swiss, 750

Included Items: Gift Box

Dimensions: Measurements of the cufflink - 16 mm x 10 mm across the top surface



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discreetly, and completely

to the customers

satisfaction.

AFFILIATIONS

These handsome cufflinks from Patek Philippe are in 18K white gold and are part of the popular Ellipse

Collection.

The surface of the cufflink has a solid gold sunburst Anthracite center.

The outer edge is set with diamonds (approx. 84 total).

These are beautiful cufflinks and will make a fantastic gift.

Curved stem with spring-closed back.

Total diamond weight - 0.40 ct.

(Click to Enlarge)

(Click to Enlarge)

International Bu yers - Please Note: Import duties, taxes and charges are not included in the item price or shipping charges. Thesecharges are the buyer's responsibility. Please check with your country's customs office todetermine what these additional costs will be prior to bidding/buying. These charges are normally collected by the delivering freight (shipping) company or when youpick the item up do not confuse them for additional shipping charges. We do not mark merchandise values below value or mark items as "gifts" - US and Internationalgovernment regulations prohibit such behavior.



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)7&;,

PXA:11 at 1Case: 1:03-cv-03904 Document #: 767-2 Filed: 10/14/13 Page 44 of 95 PageID #:13740


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Welcome and Grezi

We are professionals in relocating companies and individuals to the Greater Zurich Area. We provide the

following services:

Relocation of your company to the Greater Zurich Area

Relocation service for expats

Willkommen

Wir untersttzen Sie bei der Firmengrndung, bersiedlung und Integration in die Greater Zurich Area

Firmengrndungen und Treuhanddienstleistungen

Relocation Service

(C) 2004 - All rights reserved Print this page

Page 1 of 1

10/8/2013http://www.officepool.ch/printable/index.html

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GIN Network Truth (the smart group)OFFICE POOL GMBHThe Relocation Specialists

Lindenstrasse 20CH 8302 Kloten

Phone +41 44 815 58 58Fax +4144 815 58 59

[email protected]

House or/ and Apartment hunting

This tour is designed to meet the parameters of your personal goals.

We find you the appropriate housing.

Our services

x Pre-selection of various possibilities

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x Viewing of houses/apartments

After finding suitable accommodations, we

x check the contract before signing

x execute of take-over and move-in check list

x arrange meetings with independent insurance consultants

(private liability, house contents, medical/accident and car insurance, etc.)

x accompany you to the local authorities for registration

x help you to open a bank account

x arrange for the radio and TV, electricity, water connections

x guide you through the neighborhood and show you the nearest shopping

facilities, banks, post office, public transport, etc.x explain all the home appliances

x explain garbage disposal, quiet periods and cleaning

x explain medical system, insurance, English speaking doctors

x introduce you to professionals who speak your language

x help you to find recreational facilities, fitness and sport clubs, music andlanguage classes, service clubs, etc.

x help you get a Swiss driving license

x arrange and coordinate workmen during possible remodeling

x organize day care for your children

We dont forget you!

Our service include a 1 hour telephone hotline for the 1st month

of settling-in. Someone ill? Something break down? What to do? Call us!

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Administration

Providing financial information to our clients in a timely and accurate manner is a commitment that we feel

can not be compromised. Meaningful, well-organized financial records ensure that your business

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(C) 2004 - All rights reserved Print this page

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Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

))

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Case No. 03-C-3904


NOTICE OF MOTION FOR LEAVE TO

FILE A REPLY IN SUPPORT OF

COERCIVE INCARCERATION

To: See Attached Service List

PLEASE TAKE NOTICE that on Wednesday, October 16, 2013, at 1:30 p.m., or as soon

thereafter as counsel may be heard, Plaintiff, Federal Trade Commission, shall appear before the

Honorable Robert W. Gettleman, in the courtroom usually occupied by him, at the United States

District Court, 219 South Dearborn Street, Chicago, Illinois, and shall then and

there present Plaintiffs Motion for Leave To File a Reply in Support of Coercive Incarceration.


David OToole ([email protected])Federal Trade Commission55 West Monroe Street, Suite 1825Chicago, Illinois 60603-5001Phone: (312) 960-5601

Fax: (312) 960-5600


/s/ Jonathan CohenMichael Mora ([email protected])Jonathan Cohen ([email protected])Amanda B. Kostner ([email protected])Federal Trade Commission

600 Pennsylvania Ave., N.W. M-8102BWashington, DC 20580Phone: 202-326-3373; -2551Fax: 202-326-2558



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Kimball Richard [email protected]




/s/ Jonathan Cohen

Jonathan Cohen ([email protected])Attorney for Plaintiff

Federal Trade Commission


Trudeau Civil Case Documents 767 0 Thru 768 Re Coercive Incarceration

Documents

Transcript of Trudeau Civil Case Documents 767 0 Thru 768 Re Coercive Incarceration